Website and Services

Children's Code

At Scirra we take the protection of our customers and customer data extremely seriously and strive to provide an environment where people of all ages feel safe. To that end we work to reduce the amount of customer information we store to the minimum, we take great care of that data and only share it where that is necessary to manage our systems. We do not market our customers personal information to other businesses, and we do not profile our customers.

We store very little data about our customers and believe that Construct 3 is safe to use for Children. However, we the are very conscious of our responsibility to protect our youngest customers and to this end we set out below how we address the 15 standards of The Children’s Code set out by the ICO:

Best Interest of the Child

We do not differentiate between age groups with regard to the retention and management of personal data and so we apply all our standards equally to all users.

At the heart of our philosophy is the aim to hold the smallest amount of private information about our customers that is consistent with running our business.

Data Protection Impact Assessment

We have carried out a survey of personal data that we store and considered how critical that data is to an individual. If the recommended method using Education licenses via Access Codes is adopted then we store no student personal information at all. Otherwise, in all other cases we only store an email address relating to an owner’s account. We do not consider the storage of this information as being detrimental to a child.

We do collect some data through Google Analytics in order to determine the effectiveness and usage of Construct 3 and the web site. This data does not include any personal information.

There are three areas on the web site where risks to children could be greater. Those are the Forums, The Arcade, and The Store.

The Forums are fully moderated and monitored and we have a strict code of conduct (See Section 6) which is applicable across our web site, and which is enforced rigorously.

The Arcade contains material which is either rated as Universal or Teen. We have no adult materials on our Arcade. A click through screen is implemented to warn a user if the Arcade material is Teen rated.

All material that is available for sale in the Store is vetted before being allowed to be sold.

As a result of an earlier Data Protection Impact Assessment and in order to protect the vulnerable, we have removed Private Messaging from our web services and banned multiplayer chat games from our Arcade.

Age-Appropriate Application

We do not differentiate between age groups regarding personal data and safety. However, we have taken steps to simplify the User Interface for inexperienced users of Construct 3 though provision of the Simplified User Interface.

We have also submitted Construct 3 to the Microsoft Store and have received a UK PEGI 7+ rating for the product and content available from within it. We do not anticipate that children younger than this will utilise Construct 3.

Transparency

We have a clear Privacy Policy which references this document to make it easier for Children to understand the issues and how we address them.

There are no setting switches in our applications that would cause further personal information to be provided by a user other than the circumstance outlined in section 7.

Detrimental use of Data

We do not do anything which is detrimental to a child’s physical or mental health and wellbeing.

Policies and Community Standards

We have community guideline which are published here: https://www.construct.net/en/forum/general/open-topic-33/forum-community-guidelines-141035

And we rigorously enforce them. We lock threads and ban users when required.

We also publish guidelines for games submitted to the Arcade when a game is being submitted.

Default Settings

Education licenses are assigned by a teacher to their students. The recommended method of doing that is through setting up Access Codes so that a student may access full functionality without providing any personal information. If a teacher chooses to assign licenses directly to a student account, then the student will have previously needed to create an account with an email address, and that email address will be stored by Scirra in the normal manner.

Data Minimisation

We continually seek to minimise the private data we hold on individuals to reduce risk. The introduction of Construct 3 has led to a significant reduction in the retention of such data.

Data Sharing

We do not share any of our customer’s personal data with third parties other than the pseudo-anonymous information collected by Google for the provision of product usage analysis as outlined in section 2.

To be clear - We do NOT sell or pass on any personal information.

Geolocation

We record the country a person lives in for the purpose of providing correct sales and support information.

We have access to city level location information of our users via Google Analytics to determine regional usage of our product.

We do not record or access street level location information other than a billing address provided for purchasing as required by tax authorities.

Parental Controls

We do not implement Parental Controls

Profiling

We do not profile our users.

Nudge Techniques

We do not use any Nudge Techniques other than the provision of a “Buy Now” button that shows in several places on the Web Site and in the free version of Construct 3. This disappears from Construct 3 when it is accessed via an Access Code.

We consider that as a child will not have a payment method then this is acceptable.

Connected Toys and devices

Scirra does not provide such items

On-Line tools

We provide “report” buttons on our website for reporting bad content

We provide a support line supporthrv@construct.net where a user may interact with the Scirra support team.

A user may use this email address to request to have their personal data removed and their account terminated.